Anza v. Ideal Steel Supply Corp

In Anza v. Ideal Steel Supply Corp. (2006) 547 U.S. 451, the plaintiff, a steel company, sued its competitor, alleging that it was injured by the competitor's unlawful practice of selling products free of sales tax to cash paying customers. (Id. at p. 454.) The plaintiff alleged that this fraud enabled the competitor "to offer lower prices designed to attract more customers." (Id. at p. 458.) The United States Supreme Court found that the plaintiff's allegations were insufficient to establish standing. First, it noted that the "direct victim of this conduct was the State of New York, not the plaintiff. It was the State that was being defrauded and the State that lost tax revenue as a result." (Ibid.) Second, it found a lack of proximate cause between the defendant's RICO violation (failure to charge sales tax) and the plaintiff's injury (lost sales). It reasoned: "The injury the plaintiff alleges is its own loss of sales resulting from the defendant's decreased prices for cash-paying customers. The defendant, however, could have lowered its prices for any number of reasons unconnected to the asserted pattern of fraud. It may have received a cash inflow from some other source or concluded that the additional sales would justify a smaller profit margin. Its lowering of prices in no sense required it to defraud the state tax authority. Likewise, the fact that a company commits tax fraud does not mean the company will lower its prices; the additional cash could go anywhere from asset acquisition to research and development to dividend payouts. . . . There is, in addition, a second discontinuity between the RICO violation and the asserted injury. The plaintiff's lost sales could have resulted from factors other than the defendant's alleged acts of fraud. Businesses lose and gain customers for many reasons, and it would require a complex assessment to establish what portion of the plaintiff's lost sales were the product of the defendant's decreased prices." (Id. at pp. 458-459.)